Santander UK Plc · DRN-6034051

The complaint Mrs A and Mr A complain Santander UK Plc provided poor service when it carried out an account review. Mrs A and Mr A say this resulted in severe distress and inconvenience. What happened The facts of the complaint are well known to both parties, so I will only provide a summary of the key points. This complaint focuses on Mrs A and Mr A’s joint account, and Mr A’s sold account. Given the submissions are from Mr A, I will mainly refer to him in my review. Mrs A and Mr A held Santander accounts. In late 2023 Santander initiated a review of the accounts. This review would include Know Your Customer (KYC) checks and source of funds (SOF) checks. After contact with both Mrs A and Mr A via phone calls and the provision of information, the checks were completed by the end of December 2023. In December 2024 Santander contact Mrs A and Mr A about their account activity – these enquiries focused on credits from crypto merchants and a limited company. Mr A explained the information relating to this had already been provided in 2023. Santander stated the information already provided didn’t relate to its current enquiries. Mr A raised a formal complaint regarding the process Santander had in place and the extent of its enquiries. Mr A said the process had caused significant distress and inconvenience as phone calls had been lengthy and repetitive, and the information requested had already been provided or wasn’t available. Mr A said the threat of an account freeze caused anxiety and uncertainty. Mr A also felt the repeated requests to speak to Mrs A were unnecessary as she had confirmed Mr A dealt with their finances and she was happy for him to answer questions. Santander issued a final response letter on 23 December 2024, which apologised for any inconvenience caused but confirmed the information requests were necessary in order for it to complete its checks. A further complaint was raised regarding the on-going review, and Mr A complained about the service received during phone calls. In a response sent in late July 2025 Santander offered £75 to Mrs A and Mr A for the impact of any failings, but again explained the information requested was essential to it completing its KYC and SOF checks. Unhappy with these responses Mr A referred his complaint to our service. Mr A reiterated his concerns but also highlighted the health issues he had experienced and the provided evidence to show the detriment caused by Santander’s actions. An Investigator gathered the relevant information and in summary, made the following findings: • Santander was complying with its legal and regulatory obligations when it conducted the reviews in 2023 and 2024. • Although the second review may have felt repetitive and unnecessary, it is for Santander to decide the frequency and nature of its KYC and SOF checks. • It wasn’t unreasonable for Santander to ask for Mrs A to respond to queries. As this is a joint account there is an expectation that both account holders can be questioned.

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• Santander provided information to Mr A about being Power of Attorney if Mrs A wanted no contact. • The calls between Mr A and Santander show this was a lengthy and drawn-out process and there were some service failings. • On the whole call handlers remained professional and helpful. One call fell below reasonable standards, and compensation of £75 was awarded for this. • Mr A was concerned about account restrictions, and Santander could’ve been clearer about what it needed, especially as Mr A was pro-active and provided detailed and clear information when this was requested. • Given the impact of the service failings Santander should bring the total compensation figure to £250. Mr A disagreed with the Investigator’s opinion. He reiterated his concerns regarding their treatment by Santander, and outlined the impact on them. In order to put things right Mr A felt £750-£1,000 was an appropriate compensation amount, and in line with our service’s approach to compensation. Mr A says this was due to the repeated, pro-longed and disruptive nature of Santander’s errors. Santander agreed to the recommendation. As an agreement couldn’t be reached, the complaint has been referred to an ombudsman for a final decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. I’m very aware that I’ve summarised the events in this complaint in far less detail than Mr A has and I’ve done so using my own words. No discourtesy is intended by me in taking this approach. Instead, I’ve focussed on what I think are the key issues here. Our rules allow me to do this. This simply reflects the informal nature of our service as a free alternative to the courts. If there’s something I’ve not mentioned, it isn’t because I’ve ignored it. I’m satisfied I don’t need to comment on every individual argument to be able to reach what I think is the right outcome. I do stress however that I’ve considered everything Mr A and Santander have said before reaching my decision. I think it’s also important to set out our role. Our service has the power to informally resolve disputes. In order to meet this aim, we will gather the relevant evidence that is available and make a decision on what we consider to be fair and reasonable in the individual circumstances of a complaint. I can see Mr A has raised multiple concerns about our investigation having access to all the evidence he deems necessary. I can assure Mr A that as part of our inquisitorial remit we have obtained the evidence we consider necessary to reach a fair and reasonable outcome. It is not for either party to a complaint to dictate what this evidence is – rather it is a decision for our Investigators and then ombudsmen to make, on a case by case basis. Having reviewed all the evidence I consider relevant, I’ve reached the same outcome as the Investigator. I know Mr A feels strongly about this complaint, and I don’t undervalue how challenging he’s found dealing with Santander. I’ll explain why. Account review and KYC checks Santander has important legal and regulatory responsibilities to meet when providing accounts to customers. Those obligations are ongoing and don’t only apply when an account

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is opened. They can broadly be summarised as a responsibility to know its customer, monitor accounts, verify the source and purpose of funds, as well as detect and prevent other financial harm. It’s common practice for banks and other financial service providers to carry out regular reviews, and further KYC checks. And that is what happened here. The regulator – the Financial Conduct Authority (FCA) has set out detailed guidelines for KYC and SOF checks and the requirements each business must comply with. But it’s worth noting though that there is no set way in which the regulator requires a business to meet their KYC and SOF requirements. This means a variety of approaches is possible and each business will have their own individual procedures with respect to KYC requirements. This is to ensure each business can meet their regulatory requirements, but also have the autonomy to operate its business as it sees fit. So, whilst I’ve considered Mr A’s general comments about Santander’s approach to discharging its regulatory duties – in particular his comments about the frequency of the checks and the detail required, I haven’t seen anything to persuade me its processes were unreasonable or disproportionate. The FCA guidance also sets out requirements for ongoing monitoring and explains ongoing monitoring means scrutinising transactions to ensure that they are consistent with what the firm knows about the customer and taking steps to ensure that the firm’s knowledge about the business relationship remains current. I can see in this case Mr A says the questions around his accounts was prompted by his crypto activity – and this may have been one of many factors that prompted the reviews. I don’t consider this to be inappropriate or disproportionate. Santander is required to take steps to ensure their knowledge about their relationship with Mrs A and Mr A remained current, even if a review had been recently conducted. I therefore find Santander’s actions to be reasonable and in keeping with its wider regulatory duties. Another issue for Mr A is the repeated requests Santander made to query account details with Mrs A. Mr A says that Mrs A made it clear from the outset that Mr A could deal with the queries as he manages the finances and accounts and is aware of the crypto activity. I don’t doubt Mr A may well have been best placed to answer some of the queries, but the fact remained that these were joint accounts, and this allowed Santander to make inquiries with both account holders. It also isn’t unreasonable for Santander to expect Mrs A to have a level of awareness of the account activity and the SOF within the account. Both Mrs A and Mr A are responsible for the account, regardless of their practical roles in using and managing the account. Mrs A had her own individual profile with Santander, and the fact Mr A dealt with the accounts doesn’t mean Santander was wrong to carry out its KYC and SOF checks with her directly. So I don’t consider these requests to Mrs A by Santander to be failing. Mr A says Santander’s conduct throughout the reviews was unfair as they felt their accounts would be restricted or closed if they didn’t co-operate fully. I appreciate this process would’ve been stressful and a source of worry. However, after considering Santander’s contact with Mrs A and Mr A, I can’t see that it unfairly used this potential consequence to compel Mr A to co-operate swiftly. Rather, I find Santander made it clear what a potential consequence was of the relevant information not being provided. This is also set out in the terms and conditions of the accounts held by Mrs A and Mr A, and it is widely accepted as good industry practice for businesses such as Santander to set out the importance of co-operation with any account review and the necessary action it may take if its checks aren’t completed. In my view, setting out the details in this way is reasonable and ensures greater clarity for a customer. Compensation

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A key issue in Mr A’s complaint is what level of compensation is appropriate. Mr A says the recommended compensation fails to reflect the significant impact the review had on him – it caused severe distress and inconvenience, and impacted his health and plans, such as a holiday to Kenya. In order to award compensation, I must recognise failings on Santander’s part. A key starting point for this is the contact between Mr A and Santander during phone calls. There were numerous calls between Mr A and Santander when the reviews were conducted. In particular, during the 2024 review there were lengthy calls regarding account activity and the information required. During calls Mr A was often asked the same questions repeatedly, and he often had to repeat the information he had already sent in. In one call Mr A was asked to provide a crypto statement, despite him informing Santander the provider he used doesn’t provide statements. Given the detail Mr A had already provided, I can fully appreciate his frustration with the process. I am also aware that in some calls Mr A didn’t receive the level of service that he could reasonably expect – for example he was interrupted when speaking, and on another Mr A struggled to understand the agents and had to ask for points to be repeated. Given the lengthy process Mr A had been through, I do understand his strength of feeling regarding the service he received. Mr A was very co-operative throughout the review, and given the detailed nature of the review, I can see why he felt concerned with the outcome. The Investigator recommended compensation of £250 in total for Mrs A and Mr A. I understand Mr A doesn’t feel this amount effectively reflects the impact Santander’s failings had on them. I think it’s important to make a distinction here between the review itself overall and the service failings I’ve identified. Overall, I don’t find Santander acted unfairly in conducting its reviews and for its request for further information. As explained above, I find this was necessary in order for it to meet its regulatory duties. But I do find there were some shortcomings during the conduct of the review, and this caused Mrs A and Mr A distress and inconvenience. Reaching an award for distress and inconvenience is seldom straightforward. The issues involved are subjective by their very nature and the impact on the consumer can be difficult to determine. Our awards are not intended to be punitive for businesses, and their fundamental aim is to recognise the impact on a consumer where there have been shortcomings. Having considered the timeline of events, and Mr A’s comments I consider compensation of £250 overall to be fair. Mr A says based on our guidelines for compensation an award of £750 to £1,000 is appropriate. This amount is generally awarded where considerable distress has been caused over weeks or months. I understand Mrs A and Mr A were subject to two reviews and these spanned weeks and months. However, the failings I have identified didn’t span this entire period, and they primarily occurred during the second review, when there were multiple phone calls. Mr A will also see from the case studies that accompany our guidelines that awards in this bracket are for instances of persistent failings or where the distress and inconvenience caused has directly been caused by a business’s failings. This is not to say I haven’t carefully thought about Mr A’s comments regarding the impact on them during this time. Mr A says Santander’s review wasted time and resources, and caused significant emotional distress. Mr A also says it caused a flare up of a pre-existing medical condition. Alongside this Mr A says the review disrupted travel plans, and the overall process lacked procedural fairness. Reviews of this nature will inevitably cause a level of inconvenience – simply due to the fact detailed information will need to be provided and this will take time and resource from

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customers. I also appreciate Mrs A and Mr A were worried about the outcome of the review and felt the need to adjust travel plans and this may have contributed to the health flare up Mr A has detailed. But I can’t see there is sufficient evidence to support a greater compensation award. The health condition Mr A has referenced can be impacted by a range of factors, and any decision made to amend plans was made by Mrs A and Mr A. In my view holding Santander directly responsible for these issues would not be fair or proportionate. In summary, I recognise how strongly Mr A feels about what’s happened. I don’t doubt it has been a frustrating and worrying time. So, I realise Mr A will be disappointed by my decision. But overall, based on the evidence I’ve seen, I find the compensation outlined below to be fair. Putting things right Santander UK Plc should increase the compensation due to Mrs A and Mr A to £250 in total for the distress and inconvenience caused to them by service failings. My final decision My final decision is that I uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mrs A and Mr A to accept or reject my decision before 17 April 2026. Chandni Green Ombudsman

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